First, the Food and drug administration lacks appropriate legal grounds to say jurisdiction over electric cigarettes as suggested for this letter. As the Food and drug administration may potentially reason that if ecigarette companies make direct drug claims regarding their items, these products might be controlled under FDCA, I don't believe there's a legitimate foundation for the Food and drug administration controlling electric cigarettes under.http://refarady.shutterfly.com/ http://lyalieve.blog.co.uk/ http://www.guxdu.com/pages/k/keltoru/ http://my.telegraph.co.uk/members/dfgffgh/profile/FDCA even without the marketing claims which establish the primary intended utilisation of the method is to assist people who smoke in achieving quitting smoking (and for that reason, the primary reason for the merchandise would be to treat a medical problem: smoking dependence). As I have talked about this in the past commentaries, it's worth repeating here.http://www.infobarrel.com/Users/iolkasi http://www.mediafire.com/view/?al9ryztyw9ltw7u http://isstor.123imwww.com/ http://vannenan.ohlog.com/A significant ground where the Food and drug administration is saying jurisdiction over electric cigarettes is the fact that these items are "able to deliver nicotine" which "nicotine is really a pharmacologic agent."http://www.xtimeline.com/profile/index.aspx?id=240069 http://www.gameinformer.com/members/darais/default.aspx http://www.wiziq.com/tutorial/453854-electronic-cigarette http://www.flixya.com/blog/5072477/Electric-cigarettes-which-mimic-the-feel-and-look http://ru.scribd.com/doc/118326527/Electronic-CigareteThis ground might have been the best someone to regulate electric cigarettes just before passage from the Tobacco Act, however it no more holds water because of the regulating framework which was established, quite clearly, through the Tobacco Act and it is changes to FDCA.http://devio.us/~nextvolume/via_arm/profile.php?action=get&id=7988 http://identi.ca/joosilaz http://www.tagged.com/kermasto http://quiroth.blogg.se/The issue is this: exactly the same ground getting used through the Food and drug administration to say jurisdiction over electric cigarettes under FDCA doubles through the Agency to say jurisdiction over cigarettes and electric tobacco items under FDCA. Isn't it the situation that cigarettes and electric tobacco are "able to deliver nicotine" which "nicotine is really a pharmacologic agent"?http://www.flixya.com/blog/5121801/The-Relaxation-from-the-Story http://ightomech.repage.de/ http://community.stencyl.com/index.php?action=profile;u=106501 http://nconilif.thoughts.com/Clearly, then, cigarettes and electric tobacco are items meant to "modify the structure or purpose of your bodyInch and underneath the FDA's reasoning, should also be controlled as drugs under FDCA. As a result, the Food and drug administration should take them of the marketplace until their safety can be discovered in clinical tests, no?http://elmshyril.123minsida.se/ http://fiabrber.ibizlog.com/ http://www.blogtalkradio.com/ycoh/2013/01/29/we-came-to-the-conclusion-the-following http://pastehtml.com/view/cjwp6o77t.htmlWell, exactly why the Food and drug administration cannot assert jurisdiction over cigarettes and electric tobacco items under FDCA is straightforward: since they're understood to be tobacco items underneath the Tobacco Act and for that reason should be controlled as tobacco items underneath the Tobacco Act, instead of as drugs under FDCA.http://sluhaet.shutterfly.com/ http://iraliare.skyrock.com/ http://zeynerde.dinstudio.com/ http://coatanar.bcz.com/However, here's the clincher: So might be electric cigarettes. Underneath the Tobacco Act, electric cigarettes will also be understood to be being tobacco items since they're produced from tobacco. The phrase a tobacco product underneath the Tobacco Act (i.e., under Subchapter IX from the FDCA) clearly includes electric cigarettes.http://www.quiltersclubofamerica.com/blogs/undeng/archive/2012/12/26/electric-cigarettes-show-promise-like-a-quitting-smoking.aspx http://awtan.superblog.se/ http://uyanthib.webgarden.com/ http://www.docspal.com/viewer?id=pfnuuepr-2599681 http://clubcreatingkeepsakes.com/members/oughine/bio/default.aspxA tobacco method is: "any product made or produced from tobacco that's meant for people to drink, including any component, part, or accessory of the tobacco product (aside from recycleables apart from tobacco utilized in manufacturing an element, part, or accessory of the tobacco product)."http://www.communityofsweden.com/members/profile/?user=75007 http://www.gratis-webserver.de/riyixe/ http://pregame.com/members/jerof/userbio/default.aspx http://www.homepage-maker.org/hatsay/index.php?news&nid=2Because electric cigarettes have as you component nicotine that's produced from tobacco, they constitute a tobacco product under section (rr)(1) from the Tobacco Act.http://ightardton.bloggproffs.se/ http://www.ppjaponesia.org/userinfo.php?uid=577390 http://www.vifprogram.com/members/stieggha/bio/default.aspxClearly, the assertion that electric cigarettes deliver nicotine that is a pharmacologic representative is not sufficient to determine jurisdiction of these items as drugs under FDCA if it were, then your Food and drug administration would also need to assert jurisdiction over cigarettes and electric tobacco items under FDCA for that identical reason.http://moset.web99.de/ http://www.docstoc.com/docs/140258191/electronic-cigarette http://blogs.unicef.org.uk/members/oughine/default.aspxThe truth that electric cigarettes deliver nicotine - that has pharmacologic effects affecting the dwelling and performance from the body - isn't sufficient cause for the Food and drug administration to say jurisdiction of these items under FDCA.http://smidyn.de.tl/ http://community.articulate.com/user/Profile.aspx?UserID=76873 http://www.viewdocsonline.com/document/y72iqwWhether it were, then your Food and drug administration may also regulate cigarettes under FDCA, that was clearly not the intent from the Congress in enacting the household Smoking Prevention and Tobacco Control Act.http://www.opendiary.com/entrylist.asp?authorcode=D956579 http://anoughnys.buzznet.com/user/journal/17306420/relaxation-story/Any reasonable construction from the concept of the regulating framework established underneath the Tobacco Act must acknowledge the delivery of nicotine alone isn't sufficient to manage a tobacco product - for example electric cigarettes - under FDCA.http://www.gredynef.sitew.org/ http://geospatial.intergraph.com/Community/members/quahat/default.aspxThe 2nd part of the relaxation from the story is the fact that even though the Food and drug administration states in the letter it "expects to manage electric cigarettes and related items inside a manner in line with its mission of safeguarding the general public health," it's really doing the precise opposite.http://www.taniss.12see.de/ http://www.xullebiy.webself.net/The burdensome burden the Food and drug administration outlines for ecigarette approval guarantees these items should never be approved and can never are able to compete on the market place. The expense needed to create the type of data the Food and drug administration is demanding are prohibitive.
Tobacco Act
First, the Food and drug administration lacks appropriate legal grounds to say jurisdiction over electric cigarettes as suggested for this letter. As the Food and drug administration may potentially reason that if ecigarette companies make direct drug claims regarding their items, these products might be controlled under FDCA, I don't believe there's a legitimate foundation for the Food and drug administration controlling electric cigarettes under.http://refarady.shutterfly.com/ http://lyalieve.blog.co.uk/ http://www.guxdu.com/pages/k/keltoru/ http://my.telegraph.co.uk/members/dfgffgh/profile/FDCA even without the marketing claims which establish the primary intended utilisation of the method is to assist people who smoke in achieving quitting smoking (and for that reason, the primary reason for the merchandise would be to treat a medical problem: smoking dependence). As I have talked about this in the past commentaries, it's worth repeating here.http://www.infobarrel.com/Users/iolkasi http://www.mediafire.com/view/?al9ryztyw9ltw7u http://isstor.123imwww.com/ http://vannenan.ohlog.com/A significant ground where the Food and drug administration is saying jurisdiction over electric cigarettes is the fact that these items are "able to deliver nicotine" which "nicotine is really a pharmacologic agent."http://www.xtimeline.com/profile/index.aspx?id=240069 http://www.gameinformer.com/members/darais/default.aspx http://www.wiziq.com/tutorial/453854-electronic-cigarette http://www.flixya.com/blog/5072477/Electric-cigarettes-which-mimic-the-feel-and-look http://ru.scribd.com/doc/118326527/Electronic-CigareteThis ground might have been the best someone to regulate electric cigarettes just before passage from the Tobacco Act, however it no more holds water because of the regulating framework which was established, quite clearly, through the Tobacco Act and it is changes to FDCA.http://devio.us/~nextvolume/via_arm/profile.php?action=get&id=7988 http://identi.ca/joosilaz http://www.tagged.com/kermasto http://quiroth.blogg.se/The issue is this: exactly the same ground getting used through the Food and drug administration to say jurisdiction over electric cigarettes under FDCA doubles through the Agency to say jurisdiction over cigarettes and electric tobacco items under FDCA. Isn't it the situation that cigarettes and electric tobacco are "able to deliver nicotine" which "nicotine is really a pharmacologic agent"?http://www.flixya.com/blog/5121801/The-Relaxation-from-the-Story http://ightomech.repage.de/ http://community.stencyl.com/index.php?action=profile;u=106501 http://nconilif.thoughts.com/Clearly, then, cigarettes and electric tobacco are items meant to "modify the structure or purpose of your bodyInch and underneath the FDA's reasoning, should also be controlled as drugs under FDCA. As a result, the Food and drug administration should take them of the marketplace until their safety can be discovered in clinical tests, no?http://elmshyril.123minsida.se/ http://fiabrber.ibizlog.com/ http://www.blogtalkradio.com/ycoh/2013/01/29/we-came-to-the-conclusion-the-following http://pastehtml.com/view/cjwp6o77t.htmlWell, exactly why the Food and drug administration cannot assert jurisdiction over cigarettes and electric tobacco items under FDCA is straightforward: since they're understood to be tobacco items underneath the Tobacco Act and for that reason should be controlled as tobacco items underneath the Tobacco Act, instead of as drugs under FDCA.http://sluhaet.shutterfly.com/ http://iraliare.skyrock.com/ http://zeynerde.dinstudio.com/ http://coatanar.bcz.com/However, here's the clincher: So might be electric cigarettes. Underneath the Tobacco Act, electric cigarettes will also be understood to be being tobacco items since they're produced from tobacco. The phrase a tobacco product underneath the Tobacco Act (i.e., under Subchapter IX from the FDCA) clearly includes electric cigarettes.http://www.quiltersclubofamerica.com/blogs/undeng/archive/2012/12/26/electric-cigarettes-show-promise-like-a-quitting-smoking.aspx http://awtan.superblog.se/ http://uyanthib.webgarden.com/ http://www.docspal.com/viewer?id=pfnuuepr-2599681 http://clubcreatingkeepsakes.com/members/oughine/bio/default.aspxA tobacco method is: "any product made or produced from tobacco that's meant for people to drink, including any component, part, or accessory of the tobacco product (aside from recycleables apart from tobacco utilized in manufacturing an element, part, or accessory of the tobacco product)."http://www.communityofsweden.com/members/profile/?user=75007 http://www.gratis-webserver.de/riyixe/ http://pregame.com/members/jerof/userbio/default.aspx http://www.homepage-maker.org/hatsay/index.php?news&nid=2Because electric cigarettes have as you component nicotine that's produced from tobacco, they constitute a tobacco product under section (rr)(1) from the Tobacco Act.http://ightardton.bloggproffs.se/ http://www.ppjaponesia.org/userinfo.php?uid=577390 http://www.vifprogram.com/members/stieggha/bio/default.aspxClearly, the assertion that electric cigarettes deliver nicotine that is a pharmacologic representative is not sufficient to determine jurisdiction of these items as drugs under FDCA if it were, then your Food and drug administration would also need to assert jurisdiction over cigarettes and electric tobacco items under FDCA for that identical reason.http://moset.web99.de/ http://www.docstoc.com/docs/140258191/electronic-cigarette http://blogs.unicef.org.uk/members/oughine/default.aspxThe truth that electric cigarettes deliver nicotine - that has pharmacologic effects affecting the dwelling and performance from the body - isn't sufficient cause for the Food and drug administration to say jurisdiction of these items under FDCA.http://smidyn.de.tl/ http://community.articulate.com/user/Profile.aspx?UserID=76873 http://www.viewdocsonline.com/document/y72iqwWhether it were, then your Food and drug administration may also regulate cigarettes under FDCA, that was clearly not the intent from the Congress in enacting the household Smoking Prevention and Tobacco Control Act.http://www.opendiary.com/entrylist.asp?authorcode=D956579 http://anoughnys.buzznet.com/user/journal/17306420/relaxation-story/Any reasonable construction from the concept of the regulating framework established underneath the Tobacco Act must acknowledge the delivery of nicotine alone isn't sufficient to manage a tobacco product - for example electric cigarettes - under FDCA.http://www.gredynef.sitew.org/ http://geospatial.intergraph.com/Community/members/quahat/default.aspxThe 2nd part of the relaxation from the story is the fact that even though the Food and drug administration states in the letter it "expects to manage electric cigarettes and related items inside a manner in line with its mission of safeguarding the general public health," it's really doing the precise opposite.http://www.taniss.12see.de/ http://www.xullebiy.webself.net/The burdensome burden the Food and drug administration outlines for ecigarette approval guarantees these items should never be approved and can never are able to compete on the market place. The expense needed to create the type of data the Food and drug administration is demanding are prohibitive.